It has been held under Florida law that the requisite liability to be determined before a statutory first-party bad faith action will lie, is the liability of the carrier for coverage, along with the extent of the policyholder’s damages:
We hold that an insurer’s liability for coverage and the extent of damages, and not an insurer’s liability for breach of contract, must be determined before a bad faith action becomes ripe.
Cammarata v. State Farm Fla. Ins. Co., 152 So. 3d 606, 610 (Fla. 4th DCA 2014)(en banc).
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